Lack of Machine Guarding Again Named to OSHA’S Top 10 Most Cited Violations List

Every year around this time, the awards season kicks off with the Emmys, Golden Globes and the grand daddy of them all, the Oscars, eagerly announcing their lists of nominations. At the same time — and on a far more somber note — another roll call is issued, this one from the Occupational Safety & Health Administration (OSHA). Unlike Hollywood’s awards celebrations, however, no one wants to be nominated for OSHA’s Top Ten Most Cited Violations list, let alone take home the top prize.

OSHA revealed its 2017 Top 10 list at the National Safety Congress & Expo in the Indiana Convention Center. The top ten are:

1. Fall Protection – (1926.501): 6,072 violations
2. Hazard Communication (1910.1200): 4,176 violations
3. Scaffolding (1926.451): 3,288 violations
4. Respiratory Protection (1910.134): 3,097 violations
5. Lockout/Tagout (1910.147): 2,877 violations
6. Ladders (1926.1053): 2,241 violations
7. Powered Industrial Trucks (1910.178): 2,162 violations
8. Machine Guarding (1910.212): 1,933 violations
9. Fall Protection – Training Requirements: 1,523 violations
10. Electrical – Wiring Methods (1910.305): 1,405 violations

While reviewing the list, it is important to remain aware that the Federal Occupational Safety & Health Administration (OSHA) is a small agency. When tallied up to include its state partners, OSHA only has 2,100 inspectors who responsible for the health and safety of 130 million American workers, employed at more than 8 million work sites. This translates to about one compliance officer for every 59,000 workers. As a result, some serious injuries are not reported and thousands of potential violations go without citation or fines. In fact, numerous studies have shown that government counts of occupational injury are underestimated by as much as 50 percent. Employers are required to record all injuries meeting the OSHA’s ‘recordable injury’ criteria (except minor first-aid cases) on the OSHA 300 Log, and those meeting the ‘reportable’ criteria (e.g., hospitalizations or deaths), are to be reported to OSHA immediately, or within 24 hours of occurrence, as per the criteria defined in 29 CFR 1904. But it doesn’t mean all of them do.

MACHINE (UN)SAFEGUARDING IN TOP 10 MOST CITED VIOLATIONS
The absence of required machine safeguarding remains a perennial member of OSHA’s Top 10 Most Cited Violations, and 2017 was no exception. It was named number eight on the list with a total of 1,933 violations. These violations refer to OSHA 1910.212 for failing to have machines and equipment adequately guarded. Any machine part, function, or process that might cause injury should be safeguarded. When the operation of a machine may result in a contact injury to the operator or others in the area, the hazard should be removed or controlled.

A lack of machine safeguarding also held the dubious distinction of making the list of OSHA’s ten largest monetary penalties for the year — not once but four times. In fact, the largest proposed monetary penalty, a staggering $2.6 million (USD), arose from an incident where a worker was crushed to death while clearing a sensor fault in a robotic conveyor belt. OSHA alleges that the company failed to use energy control procedures to prevent robotic machinery from starting during maintenance. The manufacturer also was cited for exposing employees to crushing and amputation hazards as a result of improper machine guarding, plus failing to provide safety locks to isolate hazardous energy.

Despite these headline fines, the repercussions for employers putting workers in harm’s way remain small under the 1970 Occupational Safety and Health Act. The average federal fine for a serious workplace safety violation was $2,402 in fiscal year 2016, according to the most recent report by the AFL-CIO. And the median penalty for killing a worker was $6,500.

According to the most recent Bureau of Labor Statistics data, manufacturing plants reported approximately 2,000 accidents that led to workers suffering crushed fingers or hands, or had a limb amputated in machine-related accidents. The rate of amputations in manufacturing was more than twice as much (1.7 per 10,000 full-time employees) as that of all private industry (0.7). The bulk of these accidents occurred while removing jammed objects from a machine, cleaning or repairing the machine, or performing basic maintenance. These injuries were all largely preventable by following basic machine safeguarding precautions. Rockford Systems is committed to helping organizations reduce injuries and fatalities due to a lack of or non-compliant machine safeguarding. By creating a culture of safety in the workplace, Rockford Systems can help plant managers significantly reduce the number of on-the-job injuries and fatalities that occur annually, plus guard against hefty fines, lost production and increased insurance premiums.

Which leads to the question… “Where do we begin?”

TRAINING AND EDUCATION

Ignorantia juris non excusat (“ignorance of the law excuses not”). Recognizing that education is key to safety, Rockford Systems has offered its Machine Safeguarding Seminars for more than two decades. Thousands of safety professionals have attended the seminars from industries as diverse as aerospace and metal fabrication, to government and insurance.

Held ten times a year at our Rockford, Illinois headquarters, the 2.5 day seminars address key topics in safeguarding with a focus on OSHA 29 CFR and ANSI B-11 standards as they relate to specific machine applications and production requirements. Safeguarding equipment, both old and new, is not only explained in depth in the classroom, but demonstrated under power on the shop floor. Most of these machines are equipped with more than one type of safeguarding product so that attendees can see how different guards and devices can be applied.

Roger Harrison, Director of Training for Rockford Systems and an industrial safeguarding expert with over 25,000 hours of training experience, conducts the Machine Safeguarding Seminar.

>Another valuable educational resource is OSHA-10 General Industry and OSHA-30 General Industry training courses, both of which cover machine guarding. All of our training can be provided at your site, if preferred. To learn more about the Rockford Systems training curriculum, please visit https://www.rockfordsystems.com/seminars/

Rockford Systems also provides a variety of FREE machine safeguarding resources for your organization. Please visit our RESOURCES page to find videos, blogs, quick reference sheets, and more or visit our YouTube channel to download past webinar recordings.

ASSESSMENTS
If your organization is interested in safeguarding solutions, consider a Machine Risk Assessment or Machine Safeguarding Assessment as the critical first step in any machine guarding process as outlined in ANSI B11. Most assessments, but not all, follow the basic steps outlined below.

Step 1 – Provide Machine List
To get started, please provide Rockford Systems a list of all machines (manufacturer, model number, and machine description of each machine) to be assessed. This machine list is needed to determine the estimated resource requirement for the onsite audit. Upon receipt of your machine list, an Assessment Proposal will be provided, generally within 24 hours of receipt. Please email your machine list and any machine photos (optional) to sheryl.broers@rockfordsystems.com.

Step 2 – Schedule Onsite Visit
During the assessment, a machine safeguarding specialist will visit your site and conduct a complete audit of all machines identified on the list and evaluate their compliance in five guarding areas (Safeguards, Controls, Disconnects, Starters, and Covers). The assessment is based on OSHA 1910.212 General Requirements (a)(1), ANSI B11 Safety Standards for Metalworking, ANSI/RIA R15.06-2012 Safety Standards for Industrial Robots, and NFPA 79. If Rockford Systems, LLC has additional specific safeguarding requirements above and beyond OSHA 1910.212 and ANSI B11, please provide them before the site visit and we will incorporate them into the assessment.

Also, during the assessment, we may request copies of electrical, pneumatic and/or hydraulic schematics and operator manuals for specific machines. This information is needed for our Engineering Department to review the control circuit for electrical compatibility of equipment being offered, to verify control reliability of the control circuit, to determine interfacing requirements of suggested equipment. If requested, this information would be needed before advancing to Step 3 below.

Step 3 – Receive Compliance Report and Safeguarding Project Proposal
Upon completion of the assessment, a Compliance Report and Safeguarding Project Proposal will be provided to that identifies where each machine is in, or not in, compliance with the above stated regulations and standards. Where not in compliance, we will suggest guarding solutions to bring the machines into compliance, along with associated costs and timeframes.

We look forward to assisting your organization with its safeguarding needs. A team member will call you within 24 hours to further discuss your needs and applications. We are here to help businesses large and small address machine safety challenges and to remove the burden of managing the growing legal complexity of OSHA, ANSI and NFPA requirements from simple turnkey solutions to build-to-spec customized solutions.

Please contact sheryl.broers@rockfordsystems.com or call 1-815-874-3648 (direct) to get started on an assessment today.

PRODUCTS
If you are looking for Machine Safeguarding Products, please visit our PRODUCTS page that offers over 10,000 safeguarding solutions for drill presses, grinders, lathes, milling machines, press brakes, power presses, radial arm drills, riveters and welders, robots, sanders, saws and more.

RETURN ON INVESTMENT
Not sure if the investment in machine safeguarding provides a return on the investment (ROI), it absolutely does and we can help you calculate it. Please read our detailed blog post on this topic.

For more information on how avoid machine injuries and fatalities, please visit www.rockfordsystems.com.

Got Grinders? Get Safeguarding

Safeguarding Standards for Bench and Pedestal Grinders

Grinders are one of the most frequently cited machines during OSHA machine-safety inspections. This is frequently due to improperly adjusted work-rests and tongue-guards on bench/pedestal grinders, as well as a lack of ring-testing for the grinding wheels.

OSHA 29 CFR SubPart O 1910.215 is a “machine specific” (vertical) regulation with a number of requirements, which if left unchecked, are often cited by OSHA as violations. ANSI B11.9-2010 (Grinders) and ANSI B7.1 2000 (Abrasive Wheels) also apply.

Work-Rests and Tongue-Guards
OSHA specifies that work-rests must be kept adjusted to within 1/8-inch of the wheel, to prevent the workpiece from being jammed between the wheel and the rest, resulting in potential wheel breakage. Because grinders run at such a high RPM, wheels actually explode when they break, causing very serious injury, like blindness and even death.

In addition, the distance between the grinding wheel and the adjustable tongue-guard (also known as a “spark arrestor”) must never exceed 1/4-inch. Because the wheel wears down during use, both these dimensions must be regularly checked/adjusted.

“Grinder safety gauges” can be used during the installation, maintenance, and inspection of bench/pedestal grinders to make sure the work-rests and tongue-guards comply with OSHA’s 1910.215 regulation and ANSI standards. Wait until the wheel has completely stopped and the Grinder is properly “Locked Out” before using a “grinder safety gauge”. Grinder coast-down time takes several minutes, which tempts employees to use the “grinder safety gauge” while the wheel is still rotating. This practice is very dangerous because it can cause wheel breakage.

Where grinders are concerned, personal protective equipment (PPE) usually means a full face-shield, not just safety glasses. You cannot be too careful with a machine that operates at several thousand RPM.

Remember, you must DOCUMENT any and all safety requirements set forth by OSHA, as that is their best evidence that safety procedures are really being followed.

Ring-Testing
OSHA says that you must “ring-test” grinding wheels before mounting them to prevent the inadvertent mounting of a cracked grinding wheel.

Ring Testing
Ring-Testing involves suspending the grinding wheel by its center hole, then tapping the side of the wheel with a non-metallic object. This should produce a bell tone if the wheel is intact. A thud, or a cracked-plate sound indicates a cracked wheel. NEVER mount a cracked wheel.

For larger grinders, grinding wheels are laid flat on a vibration-table, with sand evenly spread over the wheel. If the wheel is cracked, the sand moves away from the crack.

To prevent cracking a wheel during the mounting procedure, employees must be very carefully trained in those procedures. This starts with making sure the wheel is properly matched to that particular grinder, using proper blotters and spacers, and knowing exactly how much pressure to exert with a torque-wrench, just to mention a few things.

This OSHA-compliant “Wheel-Cover” allows no more than 90 degrees (total) of the wheel left exposed. (65 degrees from horizontal plane to the top of wheel-cover)
Never exceed these wheel-cover maximum opening dimensions. Larger wheel-cover openings create a wider pattern of flying debris should the wheel explode. A well-recognized safety precaution on bench/pedestal grinders is to stand well off to the side of the wheel for the first full minute before using the machine. Accidents have shown that grinding wheels are most likely to shatter/explode during that first minute.

There is an OSHA Instruction Standard #STD 1-12.8 October 30, 1978 addressing the conditional and temporary removal of the “Work Rest” for use only with larger piece parts based on the condition that “Side Guards” are provided. If this may apply to your grinder(s), make sure that you read the entire thing on OSHA.gov.

Safety Information
Grinding Wheels are Safe… Use but Don’t Abuse

Do

  • Do always Handle and Store wheels in a careful manner
  • Do Visually Inspect all the wheels before mounting for possible damage
  • Do Make Sure Operating Speed of machine Does Not Exceed speed marked on wheel, its blotter or container
  • Do Check Mounting Flanges for equal size, relieved as required & correct diameter
  • Do Use Mounting Blotters when supplied with wheels
  • Do be sure Work Rest is properly Adjusted on bench pedestal, and floor stand grinders
  • Do always Use Safety Guard that covers a minimum of one-half the grinding wheel
  • Do allow Newly Mounted Wheels to run at operating speed, with guard in place, for at least one minute before grinding
  • Do always Wear Safety Glasses or some type of approved eye protection while grinding
  • Do Turn Off Coolant before stopping wheel to avoid creating an out-of-balance condition

Don’t

  • Don’t use a wheel that has been Dropped or appears to have been abused
  • Don’t Force a wheel onto a machine Or Alter the size of the mounting hole – If a wheel won’t fit the machine, get one that will
  • Don’t ever Exceed Maximum Operating Speed established for the wheel
  • Don’t use mounting flanges on which the bearing surfaces Are Not Clean, Flat And Smooth
  • Don’t Tighten the mounting nut Excessively
  • Don’t grind on the Side of conventional, straight or Type 1 wheels
  • Don’t Start the machine Until the Safety Guard is properly and securely In Place
  • Don’t Jam work into the wheel
  • Don’t Stand Directly In Front of a grinding wheel whenever a grinder is started
  • Don’t grind material for which the Wheel Is Not Designed

Source: Grinding Wheel Institute

Rockford Systems Can Help
Rockford Systems offers a wide variety of safeguarding products for grinders.

Grinder Safety Gauge

Bench Grinder Safety Gauge
The bench grinder safety gauge is laser-cut, Grade 5052 aluminum with H32 hardness. The safety yellow, durable powder-coated gauge has silk-screened text and graphics. The bench grinder safety gauge measures 2 3/4-inches wide by 2 1/4-inches high by .1000-inches thick and has a 1/4-inch hole for attachment to the bench grinder.

Standard Mount Grinder Shields
These standard mount grinder shields are available in various sizes for protection from the swarf of bench or pedestal grinders. The frames are constructed of reinforced fiber nylon or heavy cast aluminum. Each shield is furnished with a threaded support rod. The transparent portion of the standard mount grinder shields is made of high-impact resistant polycarbonate to minimize scratching and provide durability.

Direct-Mount or Magnetic-Mount Bench Grinder Shields with Flexible Arms

Double-Wheel and Single-Wheel Bench Grinder Shields
Double-wheel bench grinder shields provide protection for both wheels of the grinder with one continuous shield. The durable shield is made of clear, 3/16-inch-thick polycarbonate and measures 18-inch x 6-inch. A special shield bracket adds stability to the top of the shield. The single-wheel bench grinder shield is made of clear, 3/16-inch-thick polycarbonate and measures 6-inch x 6-inch. This sturdy, impact-resistant shield is designed for use when a single wheel needs safeguarding. These shields have a direct-mount base that attaches directly to the grinder table or pedestal.

Electrically-Interlocked Grinder and Tool Grinder Shields
Electrically Interlocked Grinder and Tool Grinder Shields
These electrically interlocked grinder and tool grinder shields are ideal for single- and double-wheel grinders. When the heavy-duty shield is swung out of position, the positive contacts on the microswitch open, sending a stop signal to the machine control. The safety microswitch electrical wires are furnished with a protective sheath and connect to the safety circuit of the machine that switches off the control to the movement of the grinding wheel. All safety micro switches are mounted in an enclosed housing with an enclosure rating of IP 67. The multi-adjustable, hexagonal steel arm structure allows easy mounting on the most diverse grinders. A versatile clamp allows horizontal and vertical adjustment of the shield. All electrically interlocked grinder and tool grinder shields consist of a high impact-resistant, transparent polycarbonate shield with an aluminum profile support and provide operator protection from flying chips and coolant.

Single-Phase Disconnect Switch

Single-Phase Disconnect Switch and Magnetic Motor Starter
This single-phase unit is designed for motors that have built-in over-loads. Typical applications for these combinations include smaller crimping machines, grinders, drill presses, and all types of saws. The 115-V, 15-A disconnect switch and non-reversing magnetic motor starter are housed in a NEMA-12 enclosure. Enclosure size is 8″ x 6″ x 3 1/2″. It includes a self-latching red emergency-stop palm button and a green motor control start push button. It can be used on machines with 115-V and is rated up to 1/2 HP maximum. The disconnect switch has a rotary operating handle which is lockable in the off position only. This meets OSHA and ANSI standards. For machines with 230-V AC single-phase motors, a transformer is required to reduce the control circuit voltage to 115-V AC in order to comply with NFPA 79.

Danger Sign for Cutting and Turning Machines
Don’t forget to post the appropriate danger signs near all machinery in the plant. The purpose of danger signs is to warn personnel of the danger of bodily injury or death. The suggested procedure for mounting this sign is as follows:
1) Sign must be clearly visible to the operator and other personnel
2) Sign must be at or near eye level
3) Sign must be PERMANENTLY fastened with bolts or rivets

Please call 1-800-922-7533 or visit www.rockfordsystems.com for more information.